Germany: MOF issues new guidance on transfer pricing
On 14 July 2021, the German Ministry of Finance (MoF) published a decree providing updated administrative principles on transfer Pricing. The new decree replaces several decrees that were passed in the past at transfer prices, in particular the
See MoreIreland: Government publishes Finance Bill 2021
On 24 June 2021, the Government released the Finance Bill for 2021, which includes new and extended measures to support businesses as declared on 1 June 2021 in the government’s Economic Recovery Plan. The main highlighting points of the Bill is
See MoreFrance: Filing due date extends for loss making companies in EEA to claim WHT refund
On 28 June 2021, the Tax Authority made an announcement that the submission deadline is postponed until 30 June 2021 for loss-making non-resident companies in the European Economic Area (EEA) to claim a refund for tax withheld on certain income,
See MoreNetherlands extends tax payment deadline on request
The Dutch government has announced to extend the period during which taxpayer can request a special tax payment extension from the Tax and Customs Administration until 1 October 2021. There are several possible situations: You already applied
See MoreGreece: Tax administration issues a Circular on tax residency and PE rules
On 25 June 2021, the Tax Administration issued a Circular E. 2130 /2021, which includes additional guidelines in relation to the application of domestic law and double tax treaty provisions with respect to tax residency and permanent establishment
See MoreGreece: BEPS MLI entry into force
On 29 June 2021, OECD has published the updated position of signatories’ countries regarding the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Accordingly, MLI entered into
See MoreMLI enters into force for Hungary
On 1 July 2021, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Hungary. The agreement has come to into effect from the first day of the fourth month
See MoreIreland: Government declares a second feedback statement on ATAD interest limitation rule
On 2 July 2021, the Finance Minister, Paschal Donohoe TD, launched a second Feedback Statement on transposition of the ATAD interest limitation ratio. The Anti-Tax Avoidance Directive (ATAD) requires Member States to introduce an interest
See MoreIreland: Finance Ministry declares for a feedback statement on ATAD anti-hybrid rule
On 2 July 2021, the Finance Minister, Paschal Donohoe TD, launched a Feedback Statement on the Anti-reverse hybrid rule. The anti-hybrid rules are largely contained in ATAD2, which extended the basic anti-hybrid provisions of the first ATAD and
See MoreDenmark: OECD publishes latest MLI position on arbitration reservation
On 29 June 2021, the OECD published a document, which contains the consolidated list of reservations and notifications made by the Kingdom of Denmark upon deposit of the instrument of ratification pursuant to Articles 28(5) and 29(1) of the
See MoreDenmark: Parliament approves ATAD amendments to CFC rules
On 3 June 2021, the Danish Parliament approved a Bill L 89 to amend the controlled foreign company (CFC) rules with the purpose of bringing them in line with the EU Anti-Tax Avoidance Directive (ATAD). The major mechanism in the Danish CFC rules
See MorePoland: MOF announces a proposal to change the transfer pricing regulation
On 28 June 2021, Poland Ministry of Finance issued a plans for taxpayer-friendly amendments to the transfer pricing regulations. The following measures have been proposed under this plan. Cancellation on the preparation of transfer pricing
See MorePoland: MOF further defers the WHT collection system to 31 December 2021
On 25 June 2021, the Polish Ministry of Finance has published a decree providing further postponed the introduction of the withholding tax pay and refund system until 31 December 2021. The obligation was originally deferred until the end of June
See MoreCroatia: BEPS MLI enters into force
On 29 June 2021, OECD has published the updated position of signatories’ countries regarding the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Accordingly, the MLI enters into
See MorePoland: MOF announces tax measures to attract foreign investment
On 14 June 2021, the Polish Ministry of Finance announced a new package of measures to encourage foreign investment in Poland. Accordingly, 95% tax exemption for dividends received by Polish holding companies after a one-year holding period,
See MoreSpain publishes an order on tax return in relation to DST
On 11 June 2021, Spain published the form 490 for the digital services tax that was approved on 9 June 2021. In this declaration, taxpayers must indicate the group to which they belong, their total income, if any, and the tax base by category of
See MoreFrance: Government presents draft Finance Bill 2021 in the National Assembly
On 2 June 2021, Government published the amended draft Finance Bill 2021 in the National Assembly, which proposes to temporally ease conditions related to the carryback mechanism applicable to tax losses. According to the Bill, companies will be
See MoreSpain publishes a decree amending Mutual Agreement Procedure (MAP)
On 8 June 2021, the Spanish government has published a Royal Decree 399/2021 which amends the Regulation on Mutual Agreement Procedures (MAP) as approved by Royal Decree 1794/2008. The decree implements three packages of initiatives to enhance
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